Finding Text
Student Financial Assistance Cluster
U.S. Department of Education
Federal Direct Student Loans 84.268
Federal Pell Grant Program 84.063
Award Year 2023
Criteria or Specific Requirement - Reporting. According to 34 CFR 690.83, Dear Colleague Letter Gen 13-13,
and Federal Register Volume 84, Number 212, November 1, 2019 an institution must submit Pell and Direct
Loan origination records and disbursement records to the Common Origination and Disbursement (COD) in a
timely and accurate manner.
Condition - The College did not ensure accurate and timely notification to the Common Origination and
Disburement (COD) website for disburement dates and amounts.
Questioned Costs - None.
Context - Out of a population of 477 records, a sample of 25 students was selected for testing. Out of these 25
students selected for testing, there were six instances in which the date of the student's award was misstated
between the institutional record and the COD. Additionally, there were two students selected where the amount
of the federal award was not consistent between the institutional records and the COD. The sample was not, and
was not intended to be, a statistically valid sample.
Effect - The COD reporting system was not accurately notified of the student award dates and amounts.
Cause - Lack of communication and oversight when reporting information on the COD website.
Identification as a Repeat Finding - 2022-002, 2021-002, 2020-004, 2019-003.
Recommendation - The College should review and update its processes and controls to ensure student records
for federal awards are properly stated on the COD website. Additionally, we recommend that a formal
reconciliation process is completed to validate the procedure is completed on a regular basis.
Views of Responsible Officials and Planned Corrective Actions - Donnelly College concurs with the finding.
The Director of Financial Aid has implemented procedures to post aid in batches and to coordinate the timing of
the postings with the Business Office. Financial Aid staff review documentation from each batch posted and
compare the data to the awards posted on COD. Each month the Director reconciles her records to COD.